Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF) Policy
1. Introduction
Novus Global s.r.o., registered in Slovakia, is committed to ensuring compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. This policy is designed to prevent the misuse of our platform for illicit activities and to ensure adherence to Slovak and EU financial regulations, including Directive (EU) 2015/849 and Act No. 297/2008 on AML/CTF.
2. Regulatory Compliance
Novus Global complies with Slovak and EU regulations, including:
- Act No. 297/2008 Coll. on Prevention of Money Laundering and Terrorist Financing.
- The 5th EU Anti-Money Laundering Directive (5AMLD).
- FATF (Financial Action Task Force) recommendations.
- Local guidelines issued by the Financial Intelligence Unit (FIU) of Slovakia.
3. Know Your Customer (KYC) & Due Diligence Measures
Novus Global follows a risk-based approach (RBA) for customer verification, which includes:
- Customer Identification: Mandatory ID verification using government-issued documents.
- Proof of Address: Recent utility bills, bank statements, or other official documents.
- Enhanced Due Diligence (EDD): Applied to high-risk customers, including politically exposed persons (PEPs).
- Ongoing Monitoring: Continuous assessment of transactions for suspicious activity.
4. Risk-Based Approach (RBA) & Transaction Monitoring
- Risk classification of users based on transaction history, geography, and profile.
- Real-time and periodic transaction monitoring to detect unusual activities.
- Screening transactions against sanction lists (EU, OFAC, UN, FATF, etc.).
- Immediate reporting of suspicious transactions to the Slovak Financial Intelligence Unit (FIU).
5. Prohibited Activities & High-Risk Transactions
Novus Global prohibits transactions involving:
- Unverified third parties and anonymous accounts.
- Cryptocurrency mixing services and high-risk jurisdictions.
- Transactions involving sanctioned entities or individuals.
- Funding sources linked to illicit activities such as drug trafficking or tax evasion.
6. Reporting & Record Keeping
- All records related to KYC, transactions, and risk assessments are retained for 5 years.
- Suspicious Activity Reports (SARs) are submitted to the Slovak FIU.
- Staff are required to immediately report any suspicious activity to the AML Compliance Officer.
7. Employee Training & Internal Controls
- Mandatory AML/CTF training programs for all employees.
- Regular updates to compliance procedures based on regulatory changes.
- Designation of a Compliance Officer responsible for AML program oversight.
8. Penalties for Non-Compliance
Failure to comply with AML/CTF regulations may result in:
- Legal actions and regulatory penalties.
- Account suspension or termination.
- Reporting to relevant authorities for further investigation.
9. Policy Updates & Amendments
This AML/CTF policy is reviewed annually and updated as necessary to ensure compliance with Slovak and international regulations.
For further inquiries or compliance-related concerns, please contact [email protected].
